Back to Toxicology: 7 key checks for a strong start to 2026
New notebooks, new schedules… and toxicology files to bring up to date. September often feels like a fresh start. After the summer break, projects pick up again, product launches accelerate, and teams get back into their usual rhythm. For toxicologists and manufacturers, it is also a good time to step back and check that the data supporting safety decisions are still up to date.
In regulatory toxicology, waiting until an update becomes urgent can quickly turn a simple review into a major reformulation project. So, what are the key checks to make for the 2026 back-to-work season?
1. Bring your regulatory monitoring up to date
Review new restrictions, CMR classifications, updates to the EU Cosmetics Regulation, and requirements for target markets. For cosmetics, CosIng is useful, but the legally applicable framework remains Regulation (EC) No 1223/2009 and its annexes. Identify changes requiring immediate action and those needing continued monitoring.
2. Give your safety files a health check
Check that formulas, concentrations, raw material specifications, toxicological data, impurity information, and conditions of use are still current. A safety assessment should remain consistent with the product actually placed on the market.
3. Ask your suppliers: “What has changed?”
A change in supplier, manufacturing process or specification can affect a toxicological assessment. Ask suppliers about new specifications, classifications, toxicological data, manufacturing changes and new information on impurities.
4. Anticipate reformulation instead of reacting to it
The TPO case showed how a regulatory change affecting one substance can have consequences for an entire formula. Replacing an ingredient is not simply deleting one INCI name: exposure, toxicological data, impurity profiles and product performance may all change. Identify alternatives early.
5. Look beyond human safety
Environmental impact is increasingly relevant. Persistence, bioaccumulation, ecotoxicity, biodegradability and substances of concern can influence formulation and raw material choices. Considering these issues early helps manufacturers anticipate regulatory developments and market expectations.
6. Give your scientific knowledge a refresh
New publications, methods, data, conferences and webinars make continuous learning essential. The goal is not to read everything, but to identify information genuinely relevant to assessments and maintain a critical view of the evidence.
7. Use AI as a tool — not as the expert
AI can help search, organise, compare and summarise information. But automated summaries cannot replace scientific assessment. AI-generated information must be checked and contextualised against reliable sources. Toxicological interpretation and safety conclusions remain the responsibility of qualified experts.
Toxi Plan’s Back-to-Work Checklist for manufacturers:
☐ Check recent regulatory developments
☐ Review existing formulas and products
☐ Request updated documentation from suppliers
☐ Identify substances that may be subject to regulatory changes
☐ Anticipate potential reformulations
☐ Check that existing safety-file data remain relevant
☐ Plan upcoming safety assessments and updates
For toxicologists:
☐ Update your regulatory monitoring
☐ Review relevant scientific publications
☐ Identify new assessment methods and approaches
☐ Refresh your knowledge of emerging substances and concerns
☐ Schedule training and expert discussions
☐ Review and streamline your monitoring tools
☐ Keep a critical eye on AI-generated information
Disclaimer:
The information provided in this article is for informational and educational purposes only. It does not constitute legal advice nor a personalized regulatory consultation. Despite the care taken in drafting this article and verifying its sources, regulations evolve regularly and may be subject to differing interpretations depending on the specific context of each company, product, or market.
Toxi Plan®, its directors, and its employees shall not be held liable for any use made of the information contained in this article without further analysis tailored to a specific situation. Any regulatory or strategic decision should be based on a specific assessment carried out by a qualified professional, with due regard to the applicable regulations, including any provisions or regulatory practices entering into force after the date of publication.